Provider Notice issued 08/09/2024

This notice announces coverage for behavioral health services provided by sub-clinical behavioral health professionals in the Federally Qualified Health Center (FQHC) setting, in accordance with Public Act 103-0102. A sub-clinical behavioral health professional is defined as an individual possessing a master’s or doctoral degree in counseling and guidance, rehabilitation counseling, social work, psychology, pastoral counseling, marriage and family therapy, or related field. The services will be covered under both the Medicaid fee-for-service (FFS) program and the HealthChoice Illinois (HCI) managed care organizations (MCOs).

The Act requires that the Department of Healthcare and Family Services (HFS) allow reimbursement to FQHCs for the services of graduate-level, sub-clinical professionals who meet the educational requirements set forth by the Department of Financial and Professional Regulation for licensed clinical social workers (LCSWs), licensed clinical professional counselors (LCPCs), licensed marriage and family therapists (LMFTs), or licensed clinical psychologists (LCPs). An individual seeking to fulfill post-degree experience requirements in order to qualify for licensing as a LCSW, LCPC, LMFT, or LCP shall also be eligible for reimbursement so long as the individual is in compliance with all applicable laws and regulations regarding supervision, including, but not limited to, the requirement that the supervised experience be under the order, control, and full professional responsibility of the individual's supervisor or that the individual is designated by a title that clearly indicates training status.

HFS recently received federal approval from the Centers for Medicare & Medicaid Services (CMS) to expand the definition of behavioral health encounters to allow for billing of services rendered by sub-clinical behavioral health professionals operating under the direct supervision of the following:

·         a psychiatrist
·         a nurse practitioner with a psychiatric specialty
·         a LCP, LCSW, LCPC, or LMFT

HFS subscribes to CMS’ definition of “direct supervision” as in 42 CFR 410.32(b)(3)(ii).

Claims may now be submitted for the services of these sub-clinical behavioral health professionals. HFS will provide systematic timely filing overrides for claims dating back to January 1, 2024, for 180 days from the date of this notice.

Questions regarding this notice may be directed to the Bureau of Professional and Ancillary Services at 877-782-5565, or the applicable HCI MCO.

Kelly Cunningham, Administrator 
Division of Medical Programs